Modern Slavery and Human Trafficking Statement

Last updated: 21 September 2026

1. Introduction and Executive Commitment

Innovate Healthcare Services Ltd ("Innovate") is committed to preventing modern slavery, human trafficking, forced labour, and unethical exploitation across all operational activities and supply chain engagements. In accordance with Section 54 of the Modern Slavery Act 2015, Cabinet Office Procurement Policy Note PPN 009 (Tackling Modern Slavery in Government Supply Chains), and the governance principles underpinning the Procurement Act 2023, this statement sets out the actions taken by Innovate to identify, mitigate, and eradicate modern slavery risks.

As an NHS-aligned organisation delivering digital transformation, infrastructure operations, and managed ICT services across acute hospital environments and primary care networks, we recognise our legal, ethical, and clinical duty to maintain transparent supply chain standards. Modern slavery and human trafficking represent severe violations of fundamental human rights; Innovate enforces a zero-tolerance baseline across all supplier interactions, subcontracting arrangements, and corporate operations.

2. Organisational Structure, Business Model, and Supply Chains

Innovate is an active private limited company (registered in England and Wales under Company Registration Number 12685407), operating as an NHS-owned specialist digital services provider. Established in December 2021, Innovate operates as a subsidiary of South Warwickshire University NHS Foundation Trust (SWFT) and a joint venture with George Eliot Hospital NHS Trust (GEH). We also deliver strategic services across the wider Foundation Group footprint, which encompasses South Warwickshire University NHS Foundation Trust, George Eliot Hospital NHS Trust, Wye Valley NHS Trust, and Worcestershire Acute Hospitals NHS Trust (WAHT).

With a workforce of more than 200 digital, technical, and service delivery specialists, Innovate manages mission-critical ICT infrastructure, enterprise service desks, cybersecurity operations, and clinical digital systems. Our operational footprint supports over 13,000 healthcare users, managing 10,000+ endpoints, 400+ clinical and administrative applications, six regional data centres holding over 4 petabytes of data, and 140+ interconnected NHS sites via secure private wide area networks.

Our supply chains fall into four primary procurement categories:

• Enterprise ICT Hardware: Provision and lifecycle refresh of user endpoints, including laptops, desktop personal computers, mobile workstations (Workstations on Wheels / LOWs), tablets, smartphones, and peripheral devices.

• Managed Print Infrastructure: Multi-Function Devices (MFDs), floor-standing workgroup printers, desktop single-function units, and specialist clinical labelling and patient wristband thermal printers.

• Infrastructure, Data Centres, and Telecoms: Server virtualisation compute, storage area networks (SAN), cloud hosting (Microsoft Azure and NHS Central Tenant), Wide Area Network (WAN) routing, and local network switching infrastructure.

• Professional and Digital Services: Specialist subcontracting support, third-party Security Operations Centre (SOC) monitoring, structured cabling, software licensing, and managed logistics.

3. Policies and Governance Framework

Innovate enforces an integrated policy framework designed to safeguard fair work practices, maintain transparent recruitment standards, and provide robust protections for personnel across our business and supply chains:

• Whistleblowing and Freedom to Speak Up Process: Provides a secure, confidential mechanism for employees, agency staff, contractors, and supply chain personnel to report suspected wrongdoing, malpractice, or human rights abuses without fear of reprisal.

• Sustainable and Ethical Procurement Process: Incorporates South Warwickshire University NHS Foundation Trust social value principles.

• Safe Recruitment and Pre-Employment Screening Policy: Mandates strict identity verification, right-to-work validation, DBS background checks (if necessary).

• Equal Opportunities and EDI Principles: Enforces fair compensation, prohibiting wage deductions, excessive working hours, and passport or document retention.

4. Supply Chain Due Diligence and Risk Assessment

Innovate applies a risk-based due diligence model to ensure that supply chain relationships reflect our statutory duties and NHS aligned values. Given the nature of managed ICT services, our risk profiling identifies the manufacture of electronic hardware and global hardware assembly lines as areas of heightened exposure to labour abuses.

Our due diligence procedures require suppliers bidding for high-value or high-risk contracts to complete comprehensive modern slavery risk evaluations. In alignment with Section 57 and Schedules 6 and 7 of the Procurement Act 2023, any supplier or subcontractor found to have committed mandatory labour exploitation offences or failing to remedy identified labour abuses will face immediate suspension, contract termination, and reporting to the Cabinet Office Procurement Review Unit (PRU).

5. Key Performance Indicators and Operational Effectiveness

To evaluate the ongoing effectiveness of our modern slavery prevention safeguards, Innovate tracks and reviews specific operational performance indicators on an annual cycle:

• Supply Chain Audit Coverage: 100% of major ICT hardware manufacturers, managed print partners, and cabling subcontractors assessed through pre-contract compliance questionnaires.

• Contractual Flow-Down Clauses: 100% of new subcontracting agreements and supplier terms incorporate explicit modern slavery termination rights and statutory 30-day payment terms in accordance with Sections 68 and 73 of the Procurement Act 2023.

• Incidents Identified and Remediated: Zero reported occurrences or suspected breaches of human trafficking, forced labour, or modern slavery across our direct workforce or active supply chain tier.

• Workforce Verification: 100% of substantive, fixed-term, and temporary staff verified through pre-employment right-to-work checks prior to placement within any hospital or healthcare site.

7. Executive Approval and Sign-Off

This Modern Slavery and Human Trafficking Statement has been formally approved by the Executive Team of Innovate Healthcare Services Ltd and constitutes our published declaration for the financial year ending 31 March 2027.